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IN THE SUPERIOR COURT
OF THE VIRGIN ISLANDS
FILED
April 07, 2022 05:14 ~M
ST-2021-RV-00005
TAMARA CHARLES IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
CLERK OF THE COURT DIVISION OF ST. THOMAS AND ST. JOHN
*********************************
IN THE MATTER OF THE ESTATE OF
CASE NO: ST-2021-RV-00005
JEFFREY E. EPSTEIN,
Originating Case No: ST-19-PB-80
Deceased.
REPLY IN SUPPORT OF MOTION FOR AWARD OF ATTORNEYS’ FEES
COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the “Epstein
Estate”), DARREN K. INDYKE and RICHARD D. KAHN (the “Co-Executors”), and submit
this reply brief in support of their Motion for Award of Attorneys’ Fees (the “Motion for Attorneys’
Fees”) dated March 4, 2022. 1
ARGUMENT
I. The Co-Executors Are Entitled To Their Attorneys’ Fees.
Despite having made the GVI Motions in the Probate Division, the GVI argues in
its opposition that (i) the Court orders denying the GVI Motions and GVI Appeal (together, the
“Orders”) are not “judgments” and a party may not receive attorneys’ fees until the entirety of the
proceedings are complete, and (ii) the Co-Executors are not the “prevailing party.” That is
incorrect. First, the GVI ignores that this is a probate matter in which the asserted need for a final
judgment resolving the proceeding is neither logical nor required by applicable statute. Second,
the GVI’s arg
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